Blue Badge eligibility assessment:Independent Review findings

Neil Taylor

Integrated Transport Planning Ltd.

Background

Extensive independent review of Blue Badge administration

and assessment good practice in England for DfT...

Review of 33 local authorities Sep ‘09 – Sep ’10

Evaluate CoE Programme Sep ‘09 – Sep ‘10

Pilot emerging good practices Sep ’10 – Jan ‘11

Prepared updated guidance for DfT June 2011

Final report published August 2011

National Blue Badge scheme data 2010 DfT Blue Badge scheme stats...

1,053,000 BB applications (418,000 new / 635,000 renewal) 86% of new / 93% of renewal applications accepted 906,000 badges issued (558,000 subject to further assessment) 349,000 successful new applications (590,550 renewal) BB acceptance rates range from 91% - 71% by region DfT estimate 300,000 medical assessments in 09/10

2011 DfT Blue Badge scheme stats..... 939,000 badges issued (571,000 subject to further assessment) 324,000 successful new applications

IMA’s influence on ‘The system’

The Blue Badge

Scheme

(National system)

Local Authority Blue Badge teams

(152 local systems)

Broad set of Blue Badge

Scheme processes

Outputs (number of badges awarded/refused)

Legislation and guidance

Localised practices

• Provide information for applicants, for example online and in printed literature.• Signpost potentially eligible people to the Blue Badge application pathway.• Raise public awareness on the Blue Badge Scheme’s purpose and who is entitled to one.

1: Scheme publicity and information

• Application forms available in print & online with clear submission mechanism• Of fer support with completing the forms & request proof of ID and address.• Anti-f raud declarations and provision of applicant’s consent to share information.

2: Handling new/renewal applications

• Processing application forms when they arrive with the local authority.• Check proof of identity/address and determine eligibility assessment pathway.

3: Eligibility determination

• Desk-based assessment of self -reported information• Telephone contact with applicant (as required)• Refer applicant for mobility assessment with OT/Physio (as required) • Seek specif ic information f rom applicant’s healthcare professional (as required)• Site visit to organisational Blue Badge applicant’s premises (as required)• Determine eligibility based on recommendations & evidence

3b: Subject to further assessment

• Check proof of entitlement

• Issue/refuse Blue Badge

3a: Without further assessment

4a: Administration of unsuccessful applications

• Write to applicant, explaining grounds for refusal and providing an opportunity for a review, or complaint• If required, lead applicant through the review or complaint process. If successful refer applicant step 4b

4b: Administration of successful applications

• Applicant to receive DfT’s ‘Blue Badge Scheme: rights and responsibilities’ leaf let and sign declaration on terms of use and awareness of their duty to return the badge if their circumstances change

• Applicant to pay Blue Badge issue fee and be promptly issued aBlue Badge & parking disc

5: Ongoing administration

• Manage standard renewals, with a reminder letter 3 months before expiry• Manage renewals of lost/damaged and stolen badges• Request badges f rom Blue Badge holders registered as deceased• Share information with parking enforcement teams where abuse of the Blue Badge is suspected

• Include Blue Badge checks in routine parking enforcement inspections• If required, monitor suspected Blue Badge abuse/f raudulent users• If required, withdraw the Blue Badge f rom f raudulent holders/users

6: Proactive Blue Badge enforcement

Critical dependencies

BB application form: Does it provide useful information about applicant’s condition? Declarations – information sharing / IMAs

Appeals procedures: Detailed refusal letter heads off many appeals Separate appeal ‘reviews’ from ‘complaints’ Only ever need to reassess following complaint against procedure No legal requirement to carry out appeals

Re-applications Does the applicant need to be reassessed? Opportunity to check fluid conditions

Early findings were bewildering... Multitude of different approaches to BB admin & assessment

Partly due to different LA organisational structures/geography

Many authorities aiming to reduce BB scheme costs...

... but some seemed to have gone too far:

We use a desk-based scoring system (‘some people probably lie’)

No IMAs at all (‘admin staff meet borderline applicants’)

No renewal reminders (‘too expensive’)

Detailed results made case for IMAs... 63% of BB applicants are subject to further assessment

Most have some form of walking impairment

Research study pilots found that using IMAs...

Reduce costs by 30% compared to GP assessments

Reduce award rates from 95% (GP) to 70%

Achieve lower rates of appeal (20% IMA, 39% GP)

Result in fewer successful appeals (21% IMA, 28% GP)

Accelerate the eligibility decision-making process

And prompted new legislation...

“In order to ensure a fairer allocation of badges, we have therefore amended legislation to prescribe that eligibility under 4(2)(f) be confirmed through use of an independent mobility assessment unless the authority is satisfied in a particular case that it would not assist it in deciding whether the applicant was eligible (i.e. that it is self-evident that the applicant is eligible or ineligible). The legislation also prescribes the use of Independent Mobility Assessments (IMAs) in assessing eligibility under 4(2)(g) which covers temporary badges to people “unable to walk or virtually unable to walk by reason of a temporary or substantial disability which is likely to last for a period of at least 12 months”.

Local Authority Circular November 2011

Other key findings also helpful... OTs/Physios are most appropriate healthcare professionals

Suggested caseloads for healthcare professionals:

Assessment: 30 mins, Decision & reporting: 10 mins

7-8 applicants /day maximum

IMAs have been implemented successfully by all types of LA

Desk-based assessments are effective filtering tools

Identify clearly eligible/ineligible applicants

Piloted approach was 91% accurate compared to IMAs

Eligibility assessment ‘Core principles’ Developed for DfT BB Scheme Guidance in England

A way of enabling DfT to emphasise to English local

authorities what should go into an assessment, without

prescribing a specific approach.

Tested through piloting and rigorous evaluation

Supported through legislation coming into force in Sept 2012

Core principles – Desk Assessments Get OTs/Physios involved in the design & staff training

Devise an objective quantitative scoring mechanism

Can be completed by (trained) administrative staff members

Require applicants to fully complete BB application form

Core principles – Desk Assessments Cross-check self-reported information on walking ability with

disability/condition and local health services accessed

Additional information can be sought by phone

Look up on a map where applicant walks to from their home

Overview of desk-based assessmentsPro’s:

Offers uniformity of outcomes

Significantly reduces assessment costs

Con’s:

Good filtering tool but not suitable for making a decision on every

applicant.

Recourse to an IMA where a decision can’t be made

Core principles – IMAs

Full design & delivery by health professionals (OT/Physio)

Check applicant’s ID at start of assessment!

Cross-check information from applicant’s application form

Observe & record the applicant’s manner of walking

Core principles – IMAs

Use functional movement tests as appropriate

Observe and time the applicant walking a known distance

Observe resting, pauses and amount of time taken to walk

MRC dyspnoea scale for breathlessness & observe

Core principles – IMAs

Ask applicant about where & how they normally walk

Consider (correct) use of walking aids – could an aid help?

Discuss (self-reported) pain and observe applicant

Core principles – IMAs

Decision is a holistic view of all information gathered...

“Consider each aspect of walking (pain, breathlessness,

speed, distance, use of walking aids and manner of walking)

first in isolation, and then in combination, to reach a decision

as to whether they combine to mean the applicant is unable

or virtually unable to walk.”

Overview of IMAs

Pro’s:

Most accurate way of determining eligibility

Applicants feel their case has been fully considered

Reduces number of consequent appeals

Con’s:

Extends the decision-making process

Expensive and time consuming for all parties

Golden rules

Always refer to the eligibility criteria for BB Scheme

Ensure your assessment regime complies with the following

hierarchy of rules/guidance:

1. Primary legislation

2. Secondary regulations

3. Code of Practice & Process Model

4. Research evidence

Neil Taylor T: 0115 988 6903ITP Nottingham E: taylor@itpworld.net

Thanks for your time today...

ITP’s independent review of Blue Badge Scheme for DfT: http://www.dft.gov.uk/publications/blue-badge-good-practice-review